US Income
Deductions: Overview and Conceptual Aspects (503 2nd)
Portfolio Description
Tax Management Portfolio, Deductions: Overview and Conceptual Aspects, No. 503-2nd, analyzes in depth the nature, concept, scope, and application of deductions, including an historical summary of the development of the concept of deductions, an analysis of the underlying constitutional issues, and a discussion of imputed deductions. In addition, each particular deduction is described, other than trade or business and for-profit activity deductions which are discussed in 505 T.M., Trade or Business Expenses and For-Profit Activity Deductions. For deductions that are the subject of other Portfolios, the description provides an overview and an introduction to the terminology and substantive requirements of the statutory or other provision that applies. For the other deductions the provision is analyzed in depth.
The analysis of the deductions is organized categorically. The major categories discussed are deductions allowable in any event (interest, taxes, charitable contributions, casualty losses, bad debts, etc.), special deductions limited to individuals (medical, alimony, cooperative housing corporation tenant-shareholder items, moving expenses, contributions to retirement savings plans, and personal and dependency exemptions), special deductions limited to corporations (dividends received, dividends paid, financial institutions, insurance companies, etc.), deductions allowed to estates and trusts, and detailed discussion of assignment of deductions and nuclear decommissioning expense deductions.
This Portfolio may be cited as Maule and Starczewski, 503-2nd T.M., Deductions: Overview and Conceptual Aspects.
James Edward Maule, B.S., University of Pennsylvania (1973); J.D., Villanova University (1976); LL.M. (Taxation), George Washington University (1979); lecturer, Villanova University Graduate Tax Program and Tax Forum CLE Programs; lecturer, Georgetown University Law Center Institute on State and Local Taxation; lecturer, Philadelphia Bar Association Tax Section; former attorney-advisor, United States Tax Court, Judge Herbert L. Chabot; former attorney-advisor, Chief Counsel to the Internal Revenue Service; former lecturer, ALI-ABA; former lecturer, Tax Management Inc. & Continuing Legal Education Satellite Network; former lecturer, Pennsylvania Bar Institute; former lecturer, The Dickinson School of Law CLE Programs; member, American Bar Association, Section of Taxation, Committee on S Corporations (Consultant and former Chair, Subcommittee on Subchapter S and State Law; former Chair, Subcommittee on Comparison of Partnerships and S Corporations; former member, Task Force on Legislative Recommendation No. 86-1); member, American Bar Association, Section of Taxation, Committee on Teaching Taxation (Chair, Subcommittee on Manuscripts and Unpublished Teaching Materials); former member, American Bar Association Tax Section Task Force on Pass-Through Entities; member, Philadelphia Bar Association Tax Section, and owner, TaxJEM Inc., publisher of computer assisted legal instruction programs; author of numerous books, monographs, and book chapters; contributor to various tax periodicals.
Lisa Marie Starczewski, B.A., Smith College (1985); J.D., Villanova University (1988); Editor-in-Chief, Villanova Law Review (1987-88); member of adjunct faculty, Villanova University School of Law; former associate, Morgan, Lewis & Bockius; Schnader, Harrison, Segal & Lewis; member, Advisory Board on U.S. Income, Tax Management Inc.; member, Philadelphia Bar Association Section of Taxation; co-author 504 T.M., Deduction Limitations: General; author, 714 T.M., Partnerships -- Allocation of Liabilities; Basis Rules; author and co-author of numerous book chapters; contributor to various tax publications.
